Haide Pack Business Guidelines 2023.8 revised
Chapter 1 General Provisions
Article 1: In order to standardize the company's commercial operations, strengthen the standardization and institutionalization of internal control mechanisms, establish a business philosophy centered on honesty and trustworthiness, law-abiding integrity, and high-quality services, effectively maintain the company's good image and reputation, establish a long-term warning mechanism for corporate governance of commercial bribery and corruption, and protect the company's interests, these detailed rules are formulated in accordance with relevant national laws and regulations.
Article 2: These detailed rules apply to all activities related to external economic exchanges of the company, including but not limited to marketing and procurement.
Article 3: These rules are applicable to all employees and stakeholders of the company, including all customers, suppliers, service providers, and contractors who have business dealings with the company.
Article 4: Purpose of Anti Commercial Bribery and Anti Corruption:
（1） Prevent and govern commercial bribery and corruption, regulate the behavior of company employees and stakeholders, prevent legal risks, and safeguard the long-term development of the enterprise;
（2） Further improve the construction of the company's anti commercial bribery related system and enhance employees' legal awareness;
（3） Improve employee quality, consciously prevent and resist commercial bribery behavior, and maintain the company's image and reputation.
Article 5: The management of preventing and controlling commercial bribery shall follow the principles of unified leadership, hierarchical responsibility, strict organization, and comprehensive governance.
(City of Qingdao downtown, Fushan Bay CBD)
Chapter 2 Prohibition of Commercial Bribery
Article 6: Commercial bribery refers to an unfair competition behavior in which cash, physical goods, and other benefits are directly or indirectly paid or received in various names, such as kickbacks, promotional expenses, promotional expenses, labor expenses, reimbursement of various expenses, and providing domestic and foreign tourism, with the purpose of obtaining commercial transaction opportunities.
Article 7: In any external commercial activities of our company, the following behaviors are prohibited:
（1） Violating regulations by giving or soliciting cash or items in the form of gifts to the other party's unit and its related personnel;
（2） Obtaining trading, service opportunities, preferential conditions, or other economic benefits through giving property in the name of donation;
（3） Providing commercial sponsorship, tourism, and other activities that violate the principle of fair competition;
（4） Provide various membership cards, consumption cards (coupons), shopping cards (coupons), and other securities;
（5） Provide and use items such as houses and cars;
（6） Provide dry shares or dividends;
（7） Giving or receiving property or other benefits through gambling, as well as borrowing promotion fees, publicity fees, advertising fees, training fees, consulting fees, technical service fees, scientific research fees, clinical fees, etc;
（8） Other violations of laws and regulations.
Article 8: The main content of carrying out anti-corruption activities against commercial bribery:
（1） Establish a leadership organization for the governance of commercial bribery and carry out the work of governance of commercial bribery.
（2） Establish a reporting box for preventing commercial bribery and publish a reporting hotline.
（3） In the process of implementing anti bribery and anti-corruption measures, the company's management department conducts investigations and undercover visits to other departments, promptly understanding the signs of preventing commercial bribery, and researching and implementing countermeasures and measures to prevent commercial bribery.
（4） Conduct investigations and research to grasp the characteristics and patterns of corrupt behavior and commercial bribery, and conduct research and recommendations in effective prevention aspects such as education and supervision
（5） Establish a reporting and evaluation system for the prevention and control of commercial bribery. Such as the regular office meeting report of the general manager, commenting on the prevention and control of commercial bribery activities, and the evaluation of the work of reporting on work and integrity of leading cadres.
Chapter 3 Management Responsibilities
Article 9: As the direct leader of the company's operation and management, the general manager shall have the following main responsibilities:
（1） Organize the company's management team to learn and master the relevant national policies and documents on anti commercial bribery, and use them to guide the company's business activities;
（2） Guide all departments to further improve their internal control systems and establish a modern business philosophy of governing enterprises in accordance with the law and managing them scientifically;
（3） Regularly listen to the management of commercial bribery in various departments and provide evaluations in conjunction with the General Manager's office meeting.
（4） For commercial bribery issues that arise in the company, it is necessary to promptly strengthen personnel allocation and supervise the self inspection and self correction of the Commercial Bribery and Corruption Governance Office.
Article 10: The Office for the Prevention and Control of Commercial Bribery shall be established as the supervisory and management department for the commitment system for preventing commercial bribery. Its main responsibilities include:
（1） Conduct corporate governance commercial bribery work in an orderly manner in accordance with relevant national policies, laws, regulations, and rules.
（2） Exercise the responsibilities of disciplinary inspection and supervision in accordance with the law, and organize special working groups to conduct audit investigations when necessary.
（3） Organize the formulation, modification, and improvement of management measures or detailed rules for corporate governance of commercial bribery.
（4） From the perspective of top-level design of internal control systems, review the various management documents developed and modified by various departments of the company, and propose suggestions for modification and improvement.
（5） Hold a quarterly meeting on the governance of commercial bribery and corruption, and promptly propose prevention suggestions to the company.
（6） We need to develop an annual study plan for the company's anti commercial bribery and anti-corruption work, and assess the registration and learning status.
（7） Review and listen to the specific implementation plans of the company's major project economic activities (including bidding and tendering work), and conduct risk assessments on the organization and implementation plans of project activities.
（8） Strengthen the supervision and management of clean and honest employment of personnel in important parts and links;
（9） Implement the 'Anti Commercial Bribery Commitment Letter', truthfully record the integrity of personnel in important parts and links, and establish records.
（10） Responsible for tracking, supervising and inspecting the company's implementation of these measures.
Article 11: Organizational composition of the Office for the Prevention and Control of Commercial Bribery:
The Office for the Prevention and Control of Commercial Bribery is located in the General Manager's Office, with the Director of the Office being the Chief Financial Officer. The team members are composed of the General Manager's Assistant and various department managers, and the daily work is the specific responsibility of an employee from the Administrative and Human Resources Department.
Article 12: In carrying out the work of controlling commercial bribery, the Office for the Prevention and Control of Commercial Bribery shall strengthen information communication and mutual cooperation with various departments, and directly submit reports to the General Manager's Office Meeting and the Shareholders' Meeting.
The Office for the Prevention and Control of Commercial Bribery shall establish a report box for the prevention of commercial bribery, with the report email consistent with the office email of its staff members. The report phone number shall be in accordance with the contact information shown in the "Company Address List".
Chapter 4 Control Responsibilities
Article 13: The responsible person shall follow the following job responsibilities:
（1） Strictly fulfill the content promised in the commitment letter;
（2） Prohibit any form of commercial bribery;
（3） Consciously accepting the management of the regulatory department (management department) for preventing commercial bribery;
（4） If the commitment is violated, obey the supervision and management department to handle it according to relevant regulations.
Article 14: Strengthen the education and evaluation of anti commercial bribery and anti-corruption, include the anti commercial bribery and anti-corruption work in the regular meeting and evaluation of the General Manager's Office, and effectively ensure that the alarm bell rings for a long time.
Article 15: Conduct anti commercial bribery and anti-corruption activities as a part of the department's work summary and report separately.
Article 16: In the annual work report of senior executives and department heads, the status of work and integrity reporting shall be separately listed, and the progress of their own and department's anti commercial bribery and anti-corruption work shall be reported.
Chapter 5 Supervision and Punishment
Article 17: Promptly address issues discovered in the prevention of commercial bribery. In the prevention of commercial bribery, various departments should promptly stop or handle any violations of discipline and regulations discovered, and report the situation to relevant departments. Those suspected of committing crimes should be transferred to judicial authorities for handling.
Article 18: Each department of the company shall strengthen the management of personnel in important positions and take their implementation of the "Commitment Letter" as an important content for inspection and assessment, as well as an important basis for appointment and dismissal.
Article 19: The administrative department of the company shall supervise and inspect the implementation of these measures based on their responsibilities and authorities, and handle or propose handling suggestions for non fulfillment of the "Commitment Letter" by personnel in important positions.
Article 20: If personnel in important positions of the company violate this procedure, corresponding punishment shall be given according to the severity of the violation and relevant regulations.
Article 21: If any personnel of the company who engage in economic activities with the company violate the anti bribery and anti-corruption provisions, their qualifications as suppliers or service providers shall be resolutely revoked. If they constitute a commercial bribery (bribery) crime, they shall be investigated for criminal responsibility by judicial authorities.
Article 22: The company encourages employees and companies with business dealings to report and expose corrupt practices. The acceptance and investigation of reports must be strictly confidential, and it is strictly prohibited to disclose the name, department, company name, and other information of the whistleblower. It is strictly prohibited to disclose the reported information to the reported person or department. When investigating and verifying the situation, the original or copy of the whistleblower materials shall not be presented, and the whistleblower shall not be exposed, Anonymous whistleblowing letters and materials shall not be authenticated in handwriting, and whistleblowing materials shall not be borrowed from the public at will.
Article 23 Penalties for Breach of Contract:
1. The amount of compensation for the decrease in company sales caused by the breach of contract shall be punished at 30 times the total profit obtained from the breach of contract.
2. The company has the right to unilaterally terminate or terminate the employment contract without any labor compensation.
